The regulatory landscape remains fragmented and unsettled. California has passed similar consent-based laws (AB 2602/AB 1836), and a federal NO FAKES Act is pending. The EU AI Act, effective August 2026, will require labeling of AI-altered content with penalties reaching €15 million. Simultaneously, the White House Executive Order issued December 11, 2025, seeks federal preemption of conflicting state AI laws—creating potential collision between state mandates and federal harmonization efforts. How these regimes will interact remains unclear.
Attorneys in fashion, advertising, and talent representation should prepare for June 2026 compliance immediately. The Model Alliance reports that 87 percent of surveyed models worry about unauthorized AI replication. Beyond labor concerns, the laws expose unresolved questions about copyright ownership of AI-designed garments, liability for deepfake marketing, and whether synthetic performers constitute deceptive trade practices. Brands and agencies operating in New York will need updated consent protocols and disclosure procedures. Expect federal action to follow state enforcement, making early compliance a hedge against stricter national standards.